8 Creighton L. Rev. 523 (1974-1975)
Constitutional Law - Standing - Supreme Court Limits Taxpayer Standing - United States v. Richardson, 94 S. Ct. 2940 (1974); Rubach, Michael J.

handle is hein.journals/creigh8 and id is 543 raw text is: CONSTITUTIONAL LAW - STANDING - SUPREME COURT LIMITS
TAXPAYER STANDING--United States v. Richardson, 94 S. Ct. 2940
(1974).
In United States v. Richardson,' the Supreme Court was poten-
tially faced with the question of whether to order the Secretary
of the Treasury to reveal the receipts and expenditures of the
Central Intelligence Agency (CIA). The disclosure issue was never
reached, however, because the plaintiff was denied standing to
assert his claim. In refusing to grant standing, the court seems
to have tightened its standards for taxpayer standing, thus ending
any possibility of an expansion of the class of persons affected.
FACTS
William  B. Richardson sought an accounting of the receipts
and expenditures of the CIA.2 In essence, he sought to have the
Central Intelligence Agency Act3 declared unconstitutional and to
obtain an order requiring the Secretary of the Treasury to pub-
lish an accounting of the CIA's expenditures. He alleged that Ar-
ticle I, Section 9, Clause 7 of the Constitution [hereinafter referred
to as the Statements and Accounts Clause] mandated such publi-
cation. That provision says:
No Money shall be drawn from the Treasury, but in
Consequence of Appropriations made by Law; and a regu-
lar Statement and Account of the Receipts and Expendi-
tures of all public Money shall be published from time to
time.
Richardson first wrote to the Government Printing Office and
the Treasury Department inquiring about the publication of the
CIA's expenses. Those offices replied that they neither had the de-
sired information nor could they readily obtain it. Consequently,
Richardson commenced this action in the United States District
Court for the Western District of Pennsylvania.4 The trial judge
1. 94 S. Ct. 2940 (1974).
2. A provision of the Central Intelligence Agency Act, 50 U.S.C. §
403f(a) (1970), permits the agency to transfer and receive funds from other
federal agencies with the approval of the Office of Management and Budget
without regard to any provisions of law limiting or prohibiting transfers
between appropriations.
3. 50 U.S.C. § 403(a) et seq. (1970).
4. 465 F.2d 844 (3d Cir. 1972).
Richardson had initiated a similar suit earlier, but it was dismissed for
lack of federal jurisdiction. [Richardson v. Sekel, 409 F.2d 3 (3d Cir.
1969), cert. denied, 396 U.S. 949 (1969).] Id. at 847 n. 1.
The jurisdiction in the present case is based upon the Mandamus and
Venue Act, 28 U.S.C. § 1361 (1970). Id. at 849.

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